TIM

February 14, 2018

MEMORANDUM

To: He>nlan James

Chief Human Resources Officer

Monique Whittington Davis, Ed. D

Deputy Superintendent

From: Michele Winston, CPA

Director Internal Audit

Re: Human Resources Staff Salary Increases Investigation

The Internal Audit Department completed an investigation into allegations of perceived inequity for salary
increases paid to Human Resources employees. The allegations were reported anonymously in Hotlines
PGCPS 17-07-0007; 17-07-0008; 17-07-0009; 17-10-0012; and 17-10-0014 The key deter-iiiinations that
resulted from this investigation are included in the attached report.

The Chief Human Resources Officer. is responsible for preparing an action plan indicating steps that will
be taken to ensure compliance with Board policies and procedures. The specific recommendations included
in the report require actions respectively by the Deputy Superintendent, Director of Employee Labor
Relations and the Equal Employment Opportunity Advisor. All responses are due, within 15 days. Please
send your signed action plan to the Internal Audit Office, Sasscer Administration Building, Attention: Jerry
Chandler, Business Analyst or via email to jerry.chandler@pgcps.org.

Enclosure

cc: Segun Eubanks, Ed. D., Board Chair

Kevin M. Maxwell, Ph. D, Chief Executive Officer
Carolyn Boston; Vice Chair, Board of Education
Shauna Battle, Es q., General Counsel
Lewis Robinson, Director, Employee Labor Relations Office
Amana T. Simmons, Esq., EEO Advisor/Title IX Coordinator
Erica Berry Wilson, Esq., Executive Director, Board of Education
Fatai Popoola, Internal Audit_Investigator II
Prince George's County Public Schools.
Internal Audit Department I Michele Winston, CPA, Director
14201 SCHOOL LANE, UPPER MARLBORO, MD 20772 Phone: 301-780-6888 Website: www.PGCPS.org
The `GREAT BY CHOICE' trademark is owned by The Good to Great Project LLC and Morten T. Hansen. Used under license
 Human Resources
Staff Salary Increases

HOTLINE CASE REPORTING: PGCPS 17-07-0007;

17-07-0008; 17-07-0009; 17-10-0012;'and 17-10-0014

February 12, 2018

 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12, 2018

Table of Contents

BACKGROUND 2
ALLEGATIONS ...2
OBJECTIVES 3
SCOPE .3
INVESTIGATIVE ACTIVITIES .3
KFY DETERMINATIONS 4
CONCLUSIONS 7
RECOMMENDATIONS 8
ACKNOWLEDGEMENT 8
RELEVANT POLICTFS AND PROCEDURES 9

CONFIDENTIAL Page 2
 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12, 2018

BACKGROUND

Internal Audit (IA) received 5 separate hotline complaints from anonymous callers alleging that
Human Resources (HR) employees were given undue salary increases. These allegations were
reported and identified as PGCPS 17-07-0007; 17-07-0008; 17-07-0009; 17-10-0012; and-
17-10-0014.

ALLEGATIONS

The following details were provided pursuant to reported hotline allegations:

1) PGCPS 17-07-0007 - An employee went from a ASASP Unit Ill Grade 28

position to a ASASP Unit Ill Grade 28 a lateral move, but received a two-step
increase. Both of these positions are within the Human huz uu,ces Department. According to the HR Salary
cafttnn guideline employees are not offered steps or an increase when malting a lateral move. An employee
?was offered a lateral grade 28 move and asked for a step increase but was told according to
t, e ~atary setting Guide it was not allowed. So HR positions are treated differently? Why?

2) PGCPS 17-07-0008._ 'Employee D' was promoted t(.

in April 2097 - moving from a grade 28 to grade 32 position. A salary increase uuuu,,ed, 'Employee ~, ju.~
received another 3 step increase in July 2097. Why there was no negotiation in effect?. Also when has o
PGCPS employee received a 3 step Increase when not moving positions? She has been in the job less than
another 3 step increase moving from 95K to over $109K. Why is HR allowed to do what
4 months, yet gets
they want with their employees, yet quote a Salary Setting Guide with offering promotions to others outside
of HR. Please review how HR is setting salaries for HR positions versus other departments - this Is not fair.
ASASP Unit 111 has missed 5 steps since 2090 - yet this person recelves that In less than 4 months'- how
can 1 receive the same?

3) PGCPS 17-07-0009 - Prior to the. former _ departure, several Human

Resources staff were given pay increases. This is unfair and a violation of Union negotiations. Pay Increases
have not been announced and given to other PGCPS employees. -

4), PGCPS 17-10-0012 -- `Employee A' was laterally transferred from a Grade 28
o a Grade 28,,' - t„hi 2097 and received a 2 step increase.
Employee E' was laterally- transferred from a Grade zu tl to a Grade 28
-" - in September 2017 and received no additional steps - why? Lateral moves ate just gnat
tawta, v ..... ..~ .,,.irease in pay - why were these latP%-"~,nsfers within HP treated differently? Is it because
'Employee A' was not retained In her position as a during the HR
reorganization in 2014? Is this HR's way of 'paying nerAack"?

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 Internal Audit Department
Human Resources
Staff. Salary Increases
Investigation Report
February 12, 2018

S) PGCPS 17-10-0014 — Employee F' a , (ASASP union was a Grade 28 step 3. On April 1,
with no job change, she received a three step increase to ' (ASASP union) Grade 28 step 6. No
one else in ASASP, unless they work in HR received a three step increase. There has been no three step
increase negotiated for ASASP that I am aware of. How does HR get to decide who gets increases? What
are some HR Partners received step increases for lateral moves? Ali of HR needs to be audited regarding
salaries and how salaries are increased.

OBJECTIVES

The objectives of the investigation were:

• To determine whether HR employees were given salary increases that did not comply
with Board of Education approvals;

® To ascertain whether salary increases given to HR employees were equitable as compared

to salary improvements given to other PGCPS staff

• To ascertain whether fraud, waste and abuse existed relative to allegatinns made

SCOPE

The investigation was based on review of relevant information, documentation, emails, etc, that
were pertinent to the allegations made. Interviews were Also conducted of HR and Payroll staff,

EWE.STIGATIVE ACTIVITIES

Investigative activities were completed relative to allegations made and the following documents
were requested and reviewed:

• Report of ASASP II and TfiI Employee Changes for the period 7/1/16 — 9/30/17
• Report of HR Salary Increases for the period 7/1/16 — 9/30/17
• Employees' Personnel Files
• Position Action Request Forms

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 Internal Audit Department
Human.Resources
Staff Salary Increases
Investigation Report
February 12, 2018

KEY DETERM NATIONS

The following Ivey determinations were made as a result of investigative activities:

1. PGCP'S 1.7-07-0007 - An employee went from a ASASP Unit 1l1 Grade 28,1 , "A
position to a ASASP Unit ll1 Grade 28 S lateral move, but receivea a twv step
increase. An employee in vas offered a lateral grade 28 move and asked for a step increase
but was told according to the Salary Setting Guide it was not allowed.

Employee A was hired February 22, 2016 at the former position of -

Grade 28, step 14 at a salary of $99,126. A Position Change tot
- end salary increase was authorized and
doemvented for Employee A, effective July 10, 2017. This represented a 2 step increase
within grade, from a Grade 28, step 14 to Grade 28, step 16, at a salary of $108,831.
The Personnel Action Sheet (PAS) indicates that the purpose was "Transfer, Replacement
for Employee B." The remarks section states, " Hence, Employee A's total
_. _ 14

increase while employed within Grade 28 was $9,705 or approximately 10% after a
period of 16 months (March 2016 to July 2017). The position is located within.

The PAS for Employee C documents a position change to Grade

28, step 7 effective January 30, 2017. The remarks stated "Lateral transfer; change in
position title only, position n1imber and costing number." Employee C was in the
position of ,-,---
, "_,rior as a Grade 28, step 7. There was no
salary increase awarded to Employee C for the position change within grade. Employee
C was initially hired May 6, 2014 at a salary of $72,392 as a Grade 28, step 6 and earned
a step increase resulting from the Board approved salary enhancements (2% July 2014)
and step increase in July 2016. These increases were in accordance with Board
approvals for all employees.

2. PGCPS 17-07-0008 —Employee D was promoted to .n

April 2017 - moving from a grade 28 to grade 32 position. A salary increase occurred. Lmpioye6 D just
received another 3 step increase in July 2017.

The PAS, for Employee D documents placement in the position of.

.. as a Grade 32, step 7 at a salary of $94,979 effective. April 3,
2017. The PAS explains that this was a promotion as well as replacement for
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 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12; 2018

Employee D, A second PAS shows a "Salary Change" effective July 1, 2017, increasing
the salary to $106,073 as Grade 32, step 10, The remarks section states, "Salary
Correction based on Organization" and was signed by thf-- - I on June 15,
2017. The increase of $11,094 {12%) represents and 3 step increase within 3 months.

3. PGCPS 17-07-0009 - Prior to the s, 'aperture, several Human

Resources staff were given pay Increases. This Is unfair and a violation of union negotiations. Pay increases
have not been announced and given to other PGCPS employees.

A review of HR salary increases for the period July 1, 2016 through September 30, 2017
revealed pay increases equivalent to 2 steps or more were provided to at least 6 HR staff
members as follows:

Emnlovee Steps
Employee A 2 ,
Employee D 3
Employee E 0
Employee F 3
Employee G 0 **
Employee H 2
Employee 1 2
Employee J 2
* Position cliaitge tvitliout salary increase
** Union group and pay table change

The Board approved a step increase in July 2016 that was paid to employees January
2017. There were no other salary enhancements announced and approved by the Board
of Education as a result of union negotiations for the period July 1, 2016• through
September 30, 2017, the period of this review. The Negotiated Agreement for
Supervisory and Administrative School Personnel for the period July 2013 through June
2016 agreement relative to salary improvements provides that a 2 step improvement be
awarded to an employee when an employee is promoted to a position on a new salary
grade. There is no language relative to step improvements provided for any other
purpose.

4. PGCPS 17-100012 — ` Emplovee A' was laterally transferred from a Grade 28

_j a Grade 28: _ __._ _.. in July 2097 and receiveu a 2 step increase.
Employee E was laterally transferred from a Grade 28 _ rrio a Grade 28 _
n Septembdr 2097 and received no additional steps. Lateral moves are just that lateral
with no increase in pay - why were these lateral transfers within HR treated .differently? Is It because

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 Internal Audit Department
Human Resources.
Staff Salary Increases
Investigation Report
February 12, 2018

`Employee A' was not retained in her position as a f during the HR

reorganization in 2094? Is this HR 's way of "paying her back"?

The PAS for Employee A indicates a 2 step increase for a position change from
y r, Grade 28, step 14 to
' Grade 28, step 16 effective July 10, 2017. Employee A was on staff as an'
at the time of the HR reorganization that occurred effective June 30, 2014,
Employee A's position was eliminated- at the time, per memorandums from the CHRO
dated March 21, 2014
. and June 24, 2014.

The PAS for Employee E indicates a Transfer effective 9/25/17 to the position of .
_ Grade 28, step 10. The purpose of the transfer was "Transfer
— Lateral" to replace Employee A per the PAS. _ The prior position was also
Grade 28, step 10. The remarks states, _ _ ~ transfer no change in salary."

5. PGCPS 17-10-0014 — Employee 1=, ; • (ASASP union) was a Grade 28 step 3. On April 1,
with no job change, she received a three step fnu,.ase t( (ASASP union) Grade 28 step 6. No
one else in ASASP, unless they work in HR received a three step increase. There has been no three step
increase negotiated for ASASP.

The PAS for Employee F indicates a salary change. from $67,441, Grade 28, step 3 to
$75,317, Grade 28, step 6. Employee F is a ) 1. The effective date for the
change is 411/) 7 The reason states, "Update / correction of salary" and was authorized
by the'' _

The Board approved a one step increase in July 2016 that was paid to ASASP employees
January 2017. There were no other salary enhancements announced and approved by the
Board as a result of union negotiations for 'the period July 1; 2016 through
September 30, 2017, . the period of this review. The Negotiated Agreement for
Supervisory and Administrative School Personnel for the period July 2013 through June
2016 agreement relative to salary improvements provides that a 2 step improvement be
awarded to an employee when an employee is promoted to a position on .a new salary
grade. There is no language relative to step improvements provided for any other
purpose.

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 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12, 2018

CONCLUSIONS

The following conclusions were made based on the result of the investigation and key
determinations:

1. PGCPS 17-07-0007 - Ar, / employee received a two step increase for a Grade 28 lateral move. An
employee in ; offered a lateral grade 28 move but was told according to the Salary
Setting Guide it was not allowed.

SUBSTANTIATED -- HR Employee A received a 2 step increase for a lateral move from the
position of ' _ — 'Grade 28, step ,14) to,
(Grade '28, step lb). IA Employee C was denied a 0-1-~7 ~rcrease
for change in position from _ P
Employee C's pay remained at Grade 28, step 7.

2. PGCPS 17-07-0008 — HR Employee D was promoted moving from grade 28 to grade 32 position and
a salary increase occurred. Subsequently Employee D received another 3 step increase July 2097.

SUBSTANTIATED - HR Employee D was promoted to the Grade. 32 effective

April 3, 2017 and received a salary increase. A second "Salary Change" equivalent to a 3
step increase (Grade 32;' step 10) was processed effective July 1, 2017. Employee D
received total salary increase of $11,094 (12%) within 3 months.

3. PGCPS 17-07-0009 - Prior to the — departure, several Human

Resources staff were given pay increases. This is unfair and a _f Union negotiations. Pay
increases have not been announced and given to other PGCPS employees;

SUBSTANTIATED - Salary increases equivalent to 2 steps or more were provided to at least

6 Human Resources staff members for the period July 1, 2016 through September 30, 2017.
These salary step increases were approved by the Salary increases were
approved by the Board for all ASASP employees effective July 1,,20].6- and paid January
2017. There were no other salary enhancements announced and approved by the Board of
Education resulting from union negotiations for the period of the review, July 1, 2016
through September 30, 2017.

4. PGCPS 17-10-0012 — HR `Employee A' received a 2 step increase fora lateral transfer for a Grade
28 position in July 2097. HR Employee E was laterally transferred from a Grade 28 position in
September 2097 and received no additional step. increases.

A MSTANTIATED -:OR Employee A received a 2 step increase for a position change front
Grade 28, step 14 to Grade 28, step 16 effective July,10, 2017. Employee A was formerly .

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 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12, 2018

on staff within at the time of the _ E reorganization that occurred effective June 30, 2014,
Employee A's position was eliminated at the time.
r
1 Employee E received a transfer effective 9/25/17 to a position withit as Grade 28,
Step 10. 1 Employee E's prior position was also Grade 28, step 10. Hence, there. were
no step increases given.

5. FGCPS 17-10-0014 — HR Employee F'received a three step increase from ASASP Grade 28 step 3 to
Grade 28 step 6. No one else in ASASP, unless they work in received a three step increase. There has
been no three step increase negotiated forASASP.

SUBSTANTIATED - HR Employee F received a salary change from Grade 28, step 3 to

Grade 28, step 6. There was not a change in position and the effective date was 4/1/17. The
BOE did not approve salary increases equivalent to 3 steps for ASASP employees during that
period.

RECOMMENDATIONS

Internal Audit recommends the - following pertaining to perceived inequity for .17-ndue salary
increases paid to HR employees;

1) Employee Labor Relations should review salary increases awarded and determine
whether respective staff were due salary improvements in accordance . with negotiated
agreements.

2) The Equal Employment Opportunity Advisor should review salary increases given outside of
Board approval and union negotiations to determine equitable treatment of PGCPS
employees including staff awarded lateral transfers as well as employees outside of Human
Resources.

3) The Deputy Superintendent should review the actions authorized by the to

detennine appropriateness. This includes consideration of whether the tad
authority to direct actions to be taken after his tenure had ended;

ACKNOWLEDGEMENT

We would like to thank and staff of Human Resources and Payroll Services for their cooperation
and assistance during the investigation.

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 Internal Audit Department
Human Resources
Staff Salary Increases
Investigation Report
February 12, 2018

RELEVANT POLICI FS AND PROCEDURES

The following policies and procedures were pertinent to the investigation:

Negotiated Agreement for Supervisory and Administrative School Personnel July 2013 through
June 2016 terms of agreement relative to salary improvements states:

An employee promoted to a position on a new salary grade will be placed on the salary step in
the new grade that would result in a salary that would be no less than the salary of a two (2)~step
increase on the scale in the previous position, but in no event shall such increase exceed the top
step of the new salary grade.

Salary tables for FY 2016 improved as follows: C. An amonnt equivalent to a step increase on
January 1, 2016 applied to base for all eligible employees that will receive a FY 2016 step
increase.

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